Two steps for contractor compliance success
Step one:
Compliance planning before award of any contract
Contractors must meet some requirements before receiving a City contract. These requirements often include:
- Affirmative Action Planning (for contracts over $100,000); and
- Small and Underutilized Business Program (SUBP) requirements (for contracts over $175,000).
Contract Compliance Division (CCD) staff will work with you to collect required information before the City awards you a contract. Before contract award, you may be required to:
- submit an affirmative action plan;
- identify workers and subcontractors you commit to using; or
- identify subcontractors you have solicited.
Here are some of the documents used to record how you will comply once work begins:
- Affirmative action plan documents;
- A pre-construction book; and
- SUBP commitment forms.
Step two:
Reporting requirements once work has begun
Contractors make commitments before contract award. Once work begins, contractors must report payments to subcontractors in the City's Contract Compliance Information Management System (CCIMS). Contractors must also report prevailing wages paid to all on-site workers in LCPtracker. CCD requires this to help verify compliance with the commitments the contractor made. CCD will check compliance throughout the contract. Failure to fulfill contract commitments may result in:
- fines,
- penalties,
- withholding of payment,
- restitution payments to workers, or
- more audits.
Contract Compliance Information Management System (CCIMS)
CCD may require contractors to report subcontractor payments in CCIMS. This helps us track progress towards the contract SUBP goals. In CCIMS, subcontractors are required to confirm payments they received. CCIMS also syncs contract information to our payroll reporting system, LCPtracker.
Contractors should familiarize themselves with CCIMS. There are monthly training sessions you can access from the CCIMS login page. Contractors should use the compliance checklist as their contract starts. This will help contractors prepare for reporting.
Access Contractor Compliance Checklist
SUBP substitutions
To avoid penalties, a contractor must get written approval from CCD before the contractor:
- substitutes an SUBP firm;
- reduces the participation of an SUBP firm; or
- removes an SUBP firm from the project.
Access SUBP Deviation Request Process
LCPtracker
CCD may require contractors to report prevailing wages, and all onsite labor hours, in LCPtracker.
Prime contractors
Prime contractors are responsible for monitoring all subcontractors’ certified payrolls in LCPtracker. Prime contractors do this using a role in LCPtracker called Prime Approver. A Prime Approver must approve all payrolls submitted for the project. Access training in LCPtracker if you need to learn about this Prime Approver role.
Guides linked below are from LCPtracker. For the most updated versions, log in to LCPtracker and access the training materials.
- Prime Approver Guide (last updated 04/01/2020)
- Useful Reports in LCPtracker (last updated 02/16/2021)
Subcontractors
Subcontractors must report certified payrolls in LCPtracker on projects when required. Subcontractors should reach out to the prime contractor for questions and assistance. Training resources are offered in LCPtracker under the training materials tab.
Access the Contractor Quick Start Guide (last updated 09/15/2020)